G.R. No. 35762 - People vs. Alcaraz y Tanyag

On May 6, 1931, Melchor Alcaraz was caught stealing an imitation concha necklace valued at P0.25 from the tienda of Haw Paw in the City of Manila.
The theft was witnessed by the on-duty policeman Bolado, who apprehended Alcaraz in the act.
The stolen trinket was identified as belonging to the tienda by its owner, Haw Paw.

At trial, Alcaraz admitted to having three prior convictions for theft within the ten years immediately preceding 1931.
Official police records from the City of Manila indicated a total of twelve theft convictions dating from 1919, when Alcaraz was a youthful offender, up to his release on June 27, 1929, confirming his status as a habitual delinquent.

When the theft was committed, as well as when the decisions in the trial courts were rendered, the Spanish Penal Code and the Habitual Delinquent Laws (Acts Nos. 3397 and 3586) were in effect.
The Revised Penal Code took effect on January 1, 1932, just prior to the case being submitted for resolution by this court.
The new Revised Penal Code expressly repealed the earlier Spanish Penal Code and associated recidivist laws, but provided retroactive provisions for felonies and misdemeanors committed prior to its effect.

Article 366 of the Revised Penal Code mandated that penalties for crimes committed before the Code’s effect should be determined under the law in force at the time of the commission, except where Article 22 provided a retroactive benefit favoring the accused.
Article 22, however, contained a critical exception by excluding habitual criminals, as defined in rule 5 of Article 62, from receiving the benefits of such retroactive provisions.
This legal innovation meant that although the Revised Penal Code would generally benefit an accused through its more favorable provisions, the habitual delinquent was excluded from these benefits.

Whether the controlling provisions of the Spanish Penal Code and the Habitual Delinquent Laws should be applied or whether the revisions in the Revised Penal Code should govern the penalty.
The comparative analysis between the older laws and the newly effective Revised Penal Code regarding the imposition of penalties for theft and habitual delinquency.

Whether the retroactive provisions of the Revised Penal Code, which favor the guilty in cases pending at the time of its enactment, could be applied to a defendant who qualifies as a habitual delinquent.
How Article 22, with its specified exception for habitual criminals, affects the application of the more lenient revised provisions to Alcaraz’s case.

Whether the imposition of a combined penalty—one year and one day of presidio correctional for theft plus an additional ten years for habitual delinquency—is commensurate with the offense committed.
Reconciling the seemingly disproportionate severity of the sentence with the legal mandate for habitual offenses.